Some companies have expressed their concern with section 16 fifth paragraph, which requires all persons to wear a one-piece flotation suit while on board a sightseeing boat. According to the Association of Arctic Expedition Cruise Operators (AECO), “the average water temperature in Longyearbyen in winter and spring is 0 °C, in summer the average temperature rises to 4 °C, and in autumn it is 2 °C. The flotation suits have not been tested or approved for the environmental conditions and water temperature in Svalbard”

The NMA invited AECO to a workshop to establish an alternative solution while we are investigating a new permanent solution that will provide the necessary safety level for the arctic waters. AECO submitted the existing procedures of Hurtigruten Cruise and Oceanwide Expeditions as representative examples of solutions that are used by the industry. The workshop was conducted according to the procedures in SOLAS chapter III regulation 38. The alternative solution we present for the 2021 season will not set precedence for the future permanent regulations. 


The following assumptions were established in the workshop: 

  • The company is responsible for the passengers’ safety, and will be liable for any injuries or fatalities, even if the passengers have to provide their own outer layer. 
  • The worst-case scenario assumed in the workshop was one capsized boat with 12 passengers and three crew members in the water, while the other small craft were fully loaded with passengers and not ready for an immediate rescue operation. 
  • The one-piece flotation suits with thermal protection class D have not been tested for the arctic climate, and a higher level of safety is necessary. 
  • “Polar clothing” provided by the passengers is not based on any recognised standards. Even though such clothes may perform well in water, neither the company nor the NMA have any ways of verifying this. However, passenger provided clothes will most likely be comfortable and have a good fit for each user, which is good for mobility on board the boats, and for preventing accidents. A good fit could also be beneficial if the person falls overboard, as it will minimise the water ingress. 
  • For tender boat operations from a mother ship, the rescue of a person overboard would be conducted within minutes. During the small craft operations, there are typically several tender boats operating together, in addition to the mother ship which can provide aid, including SOLAS approved rescue boat(s). 
  • Most expedition cruise ships in the Arctic have advanced medical equipment, medical personnel and trained staff and crew. 


Vessels that have been granted exemptions according to RSV 25-2020 do not have to provide one-piece flotation suits for their passengers and crew during small craft sightseeing operations, provided that: 

  • All passengers are informed, prior to departure, of how they should pack for their trip and the importance of the layer system and how to dress for the conditions. 
  • The company provides all passengers with a packing list which includes full body polar clothing. It is recommended that the outer layer have a 15000 mm water resistance and a highly visible red or yellow colour. 
  • The passenger’s outer layer clothes are checked and approved by the ship’s crew before the passengers are allowed to enter the small craft. A pre-trip video webinar is recommended. 
  • There is at least one dedicated rescue boat on the water at all times during operation. 
  • The passenger ship has medical personnel (a medical doctor or nurse) on board. 
  • The distance from each vessel to the mother ship shall be a maximum of 1 nautical mile. The distance can be 2.5 nautical miles if the dedicated rescue boat has on board enough thermal protective aids (TPA) for the total number of persons on board the largest sightseeing craft. 
  • Each person is wearing a lifejacket with more than 150 N buoyancy. The lifejackets shall be supplied by the company. It is recommended to use lifejackets approved to level 275 (ISO 12402-2) or a SOLAS approved lifejacket.